EU CSDDDScope

EU CSDDD (Directive (EU) 2024/1760) Scope thresholds and in scope groups

This page is for the exact thresholds and group categories, not the general summary.

Use it to build the scope section of your legal memo and the cover sheet for the due diligence program.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 21, 2026
Overview

The Directive creates three main scope routes that matter in practice: the main EU company threshold, the non-EU Union turnover threshold, and the franchising or licensing route. The current rollout dates also depend on which threshold band the company falls into.

Section 1

Main scope cohort: EU companies and EU headed groups

The general EU threshold is more than 1000 employees on average and more than EUR 450 million net worldwide turnover. The same logic can apply at ultimate parent group level where the group as a whole reaches the conditions.

This is the default route most large operating groups will analyze first.

  • Employee threshold: more than 1000 on average.
  • Turnover threshold: more than EUR 450 million worldwide.
  • Relevant both for operating companies and certain ultimate parent structures.
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Section 2

Non-EU companies with sufficient Union turnover

Third-country companies are tested by Union turnover rather than employee count. The main trigger is more than EUR 450 million net turnover generated in the Union in the relevant lookback period.

This is why non-EU headquartered groups with strong EU sales should not assume the Directive is only for Union incorporated companies.

  • Employee count is not the decisive trigger here.
  • Union turnover methodology should be documented carefully.
  • Authorized representative obligations can follow.
Section 3

Franchising and licensing route

The Directive separately captures companies and groups where franchising or licensing agreements in the Union create a common identity, a common business concept, and uniform business methods, with royalties above EUR 22.5 million and turnover above EUR 80 million.

This route matters for consumer brand, retail, and network models that otherwise look smaller on an employee basis.

  • Royalties threshold: more than EUR 22.5 million.
  • Turnover threshold: more than EUR 80 million.
  • Check both the economic numbers and the contractual business model features.
Section 4

Current application waves after the 2025 amendment

The amended timing now has a first wave from 26 July 2028 and broader application from 26 July 2029. The first wave covers the largest EU and non-EU turnover bands. The remaining in-scope categories follow from 26 July 2029.

Use the amended dates in all planning documents and mark the original dates as superseded.

  • 26 July 2028: more than 5000 employees and more than EUR 1.5 billion turnover, and the matching non-EU EU-turnover band.
  • 26 July 2029: all other in-scope companies including the EUR 450 million band and the qualifying royalties route.
  • 26 July 2027 remains the transposition deadline, not the first company application date.
Primary sources

References and citations

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